Environmental Omnibus: Will simplification accelerate circularity?

The European packaging industry is entering a new chapter. With the European Commission (EC)’s new Environmental Omnibus now published, producers face both relief and responsibility.

The proposed reforms aim to cut years of complexity, but will simplification speed up circularity or dilute ambition? The answer lies in implementation.

What is the Environmental Omnibus?

The Environmental Omnibus is a set of proposed legislative updates from the European Commission designed to cut through layers of complexity in existing EU environmental law.

It’s the eighth simplification package under the current mandate, signalling a clear push toward harmonisation. Crucially, the Omnibus doesn’t aim to rewrite environmental targets, but focuses on trimming procedural and administrative requirements. The aim is to make compliance smarter by rationalising the rulebook, accelerating strategic projects, digitising reporting and easing the burden on SMEs and businesses operating across EU countries.

Most importantly, the Omnibus proposes to remove the need for European producers selling packaged products across EU borders to appoint authorised representatives in each member state to fulfil their Extended Producer Responsibility (EPR) obligations. This would remove a long-standing barrier to the Single Market if signed into law. With this change, producers would still have to meet all EPR obligations, with the goal being to streamline compliance without weakening environmental ambition.

Yet concerns remain, with the Omnibus proposal highlighting several areas of EPR legislation for future simplifications. Proposed flexibilities, such as exemptions for hygiene and food safety, could delay reuse targets and slow progress towards a truly circular packaging economy.

Simplification vs ambition

While the intent of the Omnibus is to streamline compliance, some industry voices argue that simplification could come at a cost. By introducing additional flexibilities, there is a risk that measures designed to accelerate reuse and recyclability may be relaxed, losing their original strength and purpose.

For example:

• Exemptions for hygiene and food safety could delay reuse obligations for the takeaway sector.
• Adjustments to PFAS restrictions or recycled content requirements could weaken environmental safeguards.

These concerns highlight a delicate balance: reducing administrative burden without eroding the ambition that underpins the PPWR.

Challenges ahead

If adopted, the implementation of the proposed reforms will not be straightforward. Member States will face the task of:

• Dismantling old systems and building cross-border digital infrastructure.
• Aligning producer registers and training staff.
• Interpreting technical details such as recyclability thresholds.

Success depends on collaboration and open, machine-readable data principles, which will underpin the future digital one-stop-shop and the Circular Economy Act in 2026.

Without practical guidance on labelling, reuse targets, and application dates, changes could be interpreted inconsistently, threatening harmonisation. FAQs, templates, and delegated acts must land early, not just for compliance, but to give businesses confidence to invest in better packaging design.

In early 2025, investors managing $6.8 trillion warned the EU against weakening sustainability standards. Strong, stable regulation attracts capital for innovation. But simplification can also boost competitiveness by reducing compliance costs and accelerating market entry for greener solutions. The Omnibus sits at this crossroads, balancing ambition with practicality.

Ecosurety’s role in driving change

For Ecosurety, simplification means focusing on what truly matters:

• Helping members design packaging for recyclability.
• Optimising eco-modulation fees.
• Preparing for digital product passports.

From a regulatory perspective, clarity is critical. While concerns about potential dilution of measures are valid and deserve attention, the positive momentum created by these reforms cannot be overlooked.

For years, fragmented national rules have slowed progress and added unnecessary complexity. The Environmental Omnibus signals a shift towards harmonisation and digitalisation, steps that will enable businesses to invest confidently in sustainable packaging solutions. In short, simplification must not mean compromise, but it does represent progress towards a system that supports circularity rather than bureaucracy.

Next steps

The legislative proposal will now be submitted to the European Parliament and the Council for adoption, with proposed amendments being signed into law if accepted.

If you need more help to understand how your business could be impacted by changes to EPR legislation in the EU, simply contact our team.